The BPFs response to DEFRAs ATRm Consultation

The BPF welcomes the publication of the consultation on the Alternative Registration Model for UK REACH and the accompanying consultation on proposed changes to the restriction consultation process.

We particularly welcome the proposal to place additional emphasis on use and exposure. The BPF has advocated that the risks presented by chemicals, as opposed to their intrinsic hazard properties only, be the driver for regulatory assessment and decision making. Using risk as a trigger for further investigations and action is welcome. We also welcome the proposal to not require companies to submit hazard data that was previously submitted to the European Chemicals Agency prior to Brexit. While each registration case is different, the need for data ownership did present the possibility of significant data access costs being experienced by UK companies, especially those that had previously not taken part in EU submissions, since they would have to pay merely because the UK had left the EU. Since many BPF members are importers of chemicals, particular chemical mixtures, these companies will incur new registration responsibilities under UK REACH and potentially significant data access costs for UK REACH registrations of substances successfully registered in the EU would have been incurred. Requiring such companies, many of them SMEs, to obtain access to known data would have brought no new information to industry or regulators so at first sight the proposal presents a pragmatic solution.

We recognise that moving to a one-nation system enables some activities present in EU REACH to be removed or simplified and recognise this to be the case for the proposed changes in the restriction consultation process. We will study this and all other parts of the proposals in detail and respond to the consultation and advise our members to do so as well.

The BPFs Director General Philip Law comments:

"The plastics industry in the UK welcomes the Consultation on the ATRm which DEFRA have opened. Reducing the costs burden on industry is a positive move and maintaining as near as possible as to a level playing field is crucially important in helping companies compete in an increasingly hostile global market. This will also encourage investment in the UK. As always, the UK continues to demonstrate its pragmatic approach to regulations by focusing on a risk based system."

To learn more about REACH, use this link to register for the upoming BPF seminar: https://www.bpf.co.uk/events/reach-and-the-plastics-industry.aspx